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1 EEA Technical report No 9/2013 Reducing air pollution from electricity-generating large combustion plants in the European Union An assessment of potential emission reductions of NO X, SO 2 and dust ISSN

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3 EEA Technical report No 9/2013 Reducing air pollution from electricity-generating large combustion plants in the European Union An assessment of potential emission reductions of NO X, SO 2 and dust

5 Contents Contents Acknowledgements... 4 Executive summary Introduction Background Objectives of this report Data and methods Datasets used in this study Methodology Results and discussion Analysis of fuel type and use Comparison of 2009 NO X emissions with LCPD and IED ELVs and lower BAT AELs Comparison of 2009 SO 2 emissions with LCPD and IED ELVs and lower BAT AELs Comparison of 2009 dust emissions with LCPD and IED ELVs and lower BAT AELs Uncertainty analysis Introduction Scope of the sensitivity analysis Sensitivity analysis on the impact of parameters used to estimate the flue gas volume Sensitivity analysis on the impact of the calorific value for NO X emissions Sensitivity analysis on the impact of the calorific value for SO 2 emissions Sensitivity analysis on the impact of the calorific value for dust emissions Conclusions of the sensitivity analysis on the impact of the calorific values for emissions Conclusions Emission reduction potential of NO X, SO 2 and dust Applicability of the approach Uncertainty Glossary References Annex I Example calculations of flue gas volumes for selected fuels Annex II Detail from Platts EEPP on coal plants

6 Acknowledgements Acknowledgements This report was prepared by the European Environment Agency's (EEA) European Topic Centre for Air pollution and Climate change Mitigation (ETC/ACM). Authors of the report were Pieter Lodewijks, Hannes Pieper and Luc Van Wortswinkel (ETC partner Flemish Institute for Technological Research (VITO), Belgium). The EEA project manager was Bob Boyce. Martin Adams and Eva Goossens (EEA) are thanked for their contributions to the steering and finalisation of the report. Representatives of the European Commission and the European Environmental Information and Observation Network (EIONET) who commented on the draft version of this report are warmly thanked. 4

7 Executive summary Executive summary Background In 2008, the European Environment Agency (EEA) published a first assessment of the theoretical potential to reduce emissions of nitrogen oxides (NO X ) and sulphur dioxide (SO 2 ) from electricitygenerating large combustion plants (LCPs) (EEA, 2008). That earlier study showed that improving the environmental performance of existing LCPs by applying best available techniques potentially could have reduced NO X emissions by up to 59 %, and SO 2 emissions by as much as 80 % in the year These earlier emission reduction estimates were based on data from 450 electricity-generating LCPs in the then EU-25 that had been included in the now-discontinued European Pollutant Emission Register (EPER). Since 2004, data reported by Member States shows that emissions of NO X, SO 2 and dust from all LCPs have fallen. More specifically, between 2004 and 2009, EU-27 total emissions of NO X from the sector decreased by 30 %, of SO 2 by 53 % and of dust by 58 % (AMEC, 2012). It is important to note that not all this reduction has occurred solely due to a further implementation of best available techniques (BAT), but rather by a combination of factors also including, for example, the economic recession and its subsequent impacts on energy demand, increased uptake of renewable energy and the closure of certain power plants. This report presents results from an updated assessment of the hypothetical emission reduction potential of NO X, SO 2 and dust from European LCPs for the year This new assessment is based upon improved statistics increasing the accuracy of the analysis compared to the earlier report, notably the latest available emission and fuel-use data from 2009 reported by Member States under the Large Combustion Plant Directive (2001/80/EC) (LCPD; EU, 2001). The European Commission has proposed an enhanced focus on implementation in the context of the 7th Environment Action Programme. Filling gaps in the knowledge base in order to optimise policy responses will become increasingly important in the face of the challenges and opportunities to enhance cross-cutting policy coherence. Compared with the existing situation, emissions from LCPs are expected to further decrease in the future with the implementation of the Industrial Emission Directive (2010/75/EU) (IED; EU, 2010) and its more stringent emission limit values (ELVs) that are to be met by 2016 for existing plants. The publication of the latest 2009 LCPD dataset has therefore provided an opportunity to assess the magnitude of the difference between actual emissions reported for that year and the level of emissions that would theoretically occur were the same set of plants to achieve emission levels corresponding with the IED ELVs. For comparative purposes, the report also presents a comparison of the reported 2009 emissions with the LCPD ELVs and the lower BAT associated emission levels (BAT AELs) the latter to serve as a proxy for a potential 'maximum feasible' emission reduction. The LCP pollutants NO X and SO 2 are major contributors to acid deposition, leading to soil and freshwater acidification, which damages plants and aquatic habitats and can corrode building materials. Both pollutants also contribute to the formation of secondary particulate matter (PM) in the atmosphere following their release, while NO X also react with volatile organic compounds (VOCs) in the presence of sunlight to form ground-level ozone (O 3 ). At present, primary and secondary PM and O 3 are Europe's most problematic pollutants in terms of harm to human health (EEA, 2012a). NO X, SO 2 and dust adversely affect local air quality, but also contribute to transboundary pollution causing harm to health and environment even at distant locations. Approach This report presents an estimation of the theoretical emission reduction potential from Europe's largest thermal power plants and compares the 2009 emissions data reported under the LCPD (EEA, 2012b) with the future applicable ELVs as defined in the IED, excluding all exempted circumstances. 5

8 Executive summary Box ES.1 Legislative context Large combustion plants are defined in the EU LCP Directive (2001/80/EC) as those plants having a rated thermal input of 50 MW or greater. Emissions of three pollutants (SO 2, NO X and dust) are regulated by the directive. According to the directive's Annex VIII(B), Member States must establish a plant-by-plant inventory of the total annual SO 2, NO X and dust emissions and total annual energy input by fuel type (i.e. biomass, other solid fuels, liquid fuels, natural gas or other gases). A summary of this information must be reported to the Commission every three years; the latest available data covers In addition, the Commission has asked for the plant-by-plant data to be made available. Large combustion plants are also regulated under the Integrated Pollution Prevention and Control (IPPC) Directive (consolidated version: EU, 2008) which may lead to stricter and/or additional obligations on the plants than those required under the LCPD itself. In particular, the IPPC Directive requires installations operating activities within its scope to apply the best available techniques (BAT), i.e. the most effective and advanced stage of operations considered technically and economically viable for the sector for controlling and reducing pollution. The emission limit values in the permits have to be based on BAT, taking into account local considerations. In order to describe and define the BAT at the EU level, the European Commission develops and adopts the BAT reference documents (BREF), which serve as guidance for competent authorities when defining permit conditions. In 2006 the European Commission adopted the large combustion plant BREF (LCP BREF) which describes the BAT as well as the range of emission levels achievable by applying BAT the so-called Associated Emission Levels (AEL) with the lower end (lower BAT-AEL) being the most stringent and the upper end the least stringent. The IPPC Directive and the LCPD were superseded by the Industrial Emissions Directive (IED) (2010/75/EU) which entered into force on 6 January 2011 and which had to be transposed into national legislation by 7 January The IED regulates the emissions from LCPs by requiring the application of BAT and the BAT-AELs, set out in BAT conclusions which have a legal effect, as well as by setting mandatory 'minimum' emission limit values (ELVs) for SO 2, NO X and dust. These limit values will apply for existing combustion plants from 2016 onward, with some longer transitional periods for particular groups of plants. The European Commission is presently revising the LCP BREF, with the aim of establishing BAT conclusions, to be adopted in the course of This report does not assess the compliance of individual plants or Member States under these directives. Neither does it evaluate the implementation of the IPPC, LCPD or IED through national regulations. A comparison of the reported 2009 emissions with the LCPD ELVs and the BREF lower AELs is also provided. The 2009 LCPD dataset used is the most recent emissions dataset available for LCPs, and it also contains information on the thermal capacity of each facility, its fuel types and fuel use. Of the plants in the dataset, (48 %) met the criteria for further analysis by being identifiable as an Electricity Supply Industry (ESI) or Combined Heat and Power (CHP) plant and being operational. Of these plants, most (1 592) reported NO X emissions, reported SO 2 and reported dust. The remaining plants were not considered in the scope of this report. The LCPD covers other types of industrial combustion plants beyond ESI and CHP plants such as refineries, and iron and steel facilities. Such facilities were not included in the study. Further, 'opt-out' plants which have elected to manage their emissions via other permissible LCPD methods such as closing down after a set period were excluded, as were those where there was insufficient information to allow their classification. The 2009 LCP dataset was supplemented by data from the Platts European Energy Power Plants (EEPP) dataset (Platts, 2011) that contains technical information on most electric power plants in Europe. The Platts dataset was used to distinguish between ESI and CHP plants when sector code information was not reported in the LCP dataset, and also to improve the level of detail concerning use of 'other solid fuels' and 'biomass' at Member State level. 6

9 Executive summary Four main steps were performed in the assessment: i. determination of the thermal capacity, and fuel use per fuel type at each plant; ii. estimation of flue gas volumes; iii. calculation of the theoretical NO X, SO 2 and dust emissions for three cases: assuming that all plants have emissions not exceeding the LCPD ELVs; assuming that all plants have emissions not exceeding the IED ELVs; assuming that all plants have emissions not exceeding the BREF lower AELs; iv. comparison of the pollutant emissions calculated for each of the three cases aggregated by Member State with the reported emissions for the year The robustness of the updated assessment compared to the earlier EEA 2008 report is notably improved in two main respects: the number of plants considered in this report (1 595) is greater than the number (450) upon which the findings of the earlier report were based, which strengthens the applicability of the analysis; actual fuel-use data from the LCPD reporting is used in this study. Such data was not available when the previous reporting was performed, which meant a number of assumptions had to be made concerning the fuel type and fuel consumption at the individual plant level. The accuracy of results in the current study is therefore significantly improved. It is important to note the theoretical nature of this study. It assumes the same application of the IED ELVs (and the LCPD ELVs and the BREF lower AELs) across all plants covered, and does not consider derogations or the detailed flexibilities (temporary and permanent) that are included in the scope of the IED. For example, no differentiation was made for ESI and CHP plants addressed in National Emission Reduction Plans (NERPs) or under Member State Accession Treaty derogations. Thus, the study does not provide a detailed modelling of IED implementation. The report also does not take into account any changes that may have occurred since 2009 for example, reduced industrial activity because of the economic recession, plant closures, replacement of old plants with newer, more efficient and cleaner technologies, changes in fuel mixes, operational/management changes and evolution of abatement equipment. Results and key findings A small number of large-scale coal plants and plants co-combusting coal with other fuels dominate the reported emissions for all three pollutants. Just 50 plants (i.e. 3 % of the plants addressed in this report) contribute 50 % of NO X emissions, with 454 (28 %) responsible for 90 % of emissions. The situation is more striking for SO 2 with only 20 plants (1 %) responsible for 50 % of total emissions and 165 (10 %) contributing 90 %. For dust, just 21 plants (1 %) contribute 50 % and 175 (11 %) contribute 90 % of the total reported emissions. In general, a good correlation is noted at the Member State level between the 2009 emissions reported under the LCPD for the electricity generation sector and those reported under the European Pollutant Release and Transfer Register (E-PRTR) ( 1 ), although some potential errors in official reporting were identified and are described. Unfortunately, a detailed plant-by-plant comparison is not possible because there is no direct link established between the two datasets ( 2 ). The results of the present study clearly indicate that EU-27 emissions of the air pollutants NO X, SO 2 and dust from the selected LCPs could potentially be significantly lower if all plants operating in 2009 were to meet the ELVs set out in the IED (Table ES.1 and Figure ES.1). Specific findings of the report are listed below. EU-27 NO X emissions from LCPs considered in this study have the potential to be 36 % lower than in 2009 if all plants meet the IED ELVs and 69 % lower if plants achieve the more stringent BAT AEL. For SO 2, the potential emission reductions are 66 % and 94 %, respectively, and 64 % and 79 %, respectively, for dust. Most of the potential reduction can be achieved from just a relatively few very large coal and coal co-combustion plants. Several Member States already report emissions from LCPs below the level of the IED emission limits that have to be achieved by However, in some of the newer Member States, emissions are still significantly above the IED levels. ( 1 ) European Pollutant Release and Transfer Register (http://prtr.ec.europa.eu/). ( 2 ) Under future reporting by Member States concerning their implementation of the IED, establishing such a link should be facilitated. 7

10 Executive summary At the Member State level, most of the reported 2009 emissions are consistent with, or below, the LCPD ELVs. There are a number of derogations (exemptions) granted under the LCPD that are not taken into account in this analysis, such a plants granted longer transitional periods and/or which rely on derogations such as controls on desulphurisation rates being implemented in place of attaining ELVs. It is clear that meeting the ELVs of the IED would reduce emissions of SO 2 and dust from these LCPs by more than 60 % compared to 2009 emission levels. Such reduction of emissions would obviously deliver substantial benefits in terms of improvements to human health and the environment. A recent assessment from the EEA showed that the estimated damage costs to health and the environment caused by air pollution from the energy-generating sector (excluding carbon dioxide (CO 2 )) in 2009 was EUR billion (EEA, 2011). An assessment of the costs to industry and consumers to achieve such lower emissions is beyond the scope of this report. In the following figures comparisons are made by Member State between reported emissions for 2009 and the theoretical application of ELVs for NO X (Figure ES.2), SO 2 (Figure ES.3) and dust (Figure ES.4). NO X Germany, Poland and the United Kingdom report the highest 2009 NO X emissions from LCPs (Figure ES.2). However, emissions from Germany are already largely consistent with the IED ELVs, while some scope exists to reduce emissions further to the levels of the lower BAT AELs values. Greece, Poland, Spain and the United Kingdom have the largest absolute differences in terms of tonnes of NO X from 2009 emissions to the IED ELVs. SO 2 Bulgaria, Greece, Poland and Romania have the highest reported 2009 SO 2 emissions of the EU-27 Member States (Figure ES.3), and together account for the largest difference between 2009 emission levels and the IED ELVs. In particular, Bulgaria and Romania together, contribute almost 40 % to the total SO 2 emissions for the EU-27 and, similarly, account for a large fraction of the EU-27 SO 2 emissions that in 2009 lay above the IED ELVs. Dust The same four Member States (i.e. Bulgaria, Greece, Poland and Romania) also reported the highest 2009 dust emissions, significantly above emission levels that would be consistent with the IED ELVs (Figure ES.4). Table ES.1 Gap between 2009 emissions and emissions based on the LCP emission limits, the IED emission limits, and the lower BAT AELs, by pollutant for the plants assessed in this report (*) Reported emissions 2009 Emissions (kt) Potential emissions based on LCPD ELVs Emissions (kt) % reduction compared to 2009 emissions Potential emissions based on IED ELVs Emissions (kt) % reduction compared to 2009 emissions Potential emissions based on lower BAT AELs Emissions (kt) % reduction compared to 2009 emissions NO X % % % SO % % % Dust % % % Note: * Care is needed when interpreting the values in Table ES.1 as there are uncertainties inherent in the estimation of the flue gas volumes. The estimates are based on Member State averages and do not reflect individual plants; existing LCP derogations have not been taken into account. 8

11 Executive summary Figure ES.1 Reported 2009 EU-27 LCP emissions compared with the future emission limit values of the IED, the existing LCPD emission limit values and the LCP BREF lower AEL Emissions (kt) NO X SO 2 0 Dust 2009 emissions Lower BAT AEL IED ELV LCP ELV Uncertainties Due caution is also needed when interpreting the figures since there are uncertainties inherent in the estimation of the flue gas volumes, and the estimates are averaged for each Member State thus not reflecting individual plants. Recognising the uncertainty inherent in the assessment, a sensitivity analysis was performed concerning the influence of the fuel calorific values used to estimate the flue gas volumes and, hence, ultimately the emissions. The analysis showed that the highest impact on the certainty of the study results is related to lignite and its wide range of possible calorific values. In order to raise the overall certainty for future assessments and to assist in the verification of plant emissions, it would be beneficial if plant-specific information on the calorific value of fuels used were made publicly available. 9

15 Introduction 1 Introduction 1.1 Background LCPs are a significant source of emissions of the air pollutants NO X, SO and dust (particulate matter) 2 as well as other pollutants such as greenhouse gases, heavy metals and certain persistent organic pollutants. The pollutants NO X and SO 2 are major contributors to acid deposition, leading to soil and freshwater acidification, which damages plants and aquatic habitats, and can corrode building materials. Both pollutants also contribute to the formation of secondary PM in the atmosphere following their release, while NO X also react with VOCs in the presence of sunlight to form ground level O 3. At present, primary and secondary PM and O 3 are Europe's most problematic pollutants in terms of harm to human health (EEA, 2012b). NO X, SO 2 and dust adversely affect local air quality, but also contribute to transboundary pollution causing harm to health and environment even at distant locations. The introduction of air pollution legislation over the past decades and the subsequent implementation of emission prevention and abatement measures in the power plant sector has led to a significant reduction in the level of emissions from LCPs. Since 2004, data reported by Member States shows that emissions of NO X, SO 2 and dust from plants covered by the LCP Directive have fallen significantly. More specifically, between 2004 and 2009, EU-27 emissions of NO X from the sector decreased by 30 %, of SO 2 by 53 % and of dust by 58 % (AMEC, 2012). However, despite the reductions in emissions that have occurred, the electricity and heat production sector still remains an important source of key air pollutants that contribute to poor air quality in Europe (EEA, 2012a) EU legislation concerning large combustion plants The LCPD (2001/80/EC) covers combustion plants with a rated thermal input equal to or exceeding 50 MW which are operated for power and/or heat generation purposes as well as certain industrial plants. It entered into force on 27 November The directive sets specific ELVs for the pollutants SO 2, NO X and dust (PM). The directive distinguishes between new plants (licensed after 1 July 1987), which had to meet the LCPD ELVs immediately, and existing plants (licensed before 1 July 1987), which could choose, by 1 January 2008, to: meet the LCPD ELVs, or implement a national emission reduction plan (NERP), which sets an annual maximum level of emissions for the plants covered by it. A NERP has been implemented by 8 Member States ( 3 ) for part or all of their existing LCPs. In addition, existing plants can be exempted from compliance with the emission limits and from inclusion in the NERP on condition that the operator undertook not to operate the plant for more than hours between 1 January 2008 and 31 December In 2009, there were approximately 239 such plants, and these are referred to as 'opted out' plants. The IPPC Directive (originally 96/61/EC, but consolidated in 2008 as Directive 2008/1/EC) covers a number of industrial activities (including combustion plants with a rated thermal input exceeding 50 MW) and aims to reduce their overall environmental impact through a process of integrated permitting. Emission limit values set in those permits have to be based on best available techniques (BAT), taking into account certain local considerations. The interaction between the IPPC Directive and the LCPD is such that the latter sets ( 3 ) These Member States are Czech Republic, France, Finland, Greece, Ireland, Portugal, Spain and the United Kingdom. 13

16 Introduction minimum obligations which are not necessarily sufficient to comply with the IPPC Directive. The IPPC Directive and the LCPD are being replaced by the IED (2010/75/EU) is a recast of seven existing directives. The IED entered into force on 6 January 2011 and had to be transposed into national legislation by Member States by 7 January The IED aims to achieve further benefits to the environment and human health by reducing harmful industrial emissions through the better application of BAT. Amongst the key changes is a stricter definition of BAT, leaving less flexibility for competent authorities to set ELVs outside the BAT ranges. The IED also has tighter minimum ELVs for LCPs to be applied from 1 January 2016 for existing plants. There is also the possibility under the IED of using minimum desulphurisation rates or less strict ELVs in case of plants having a limited number of operating hours. These options are not considered for the purposes of the hypothetical assessment described in this report Best available techniques and emission limits The present LCP BREF was adopted in 2006 following an exchange of information between the European Commission, the Member States, industry and environmental NGOs (European Commission, 2006). The BAT associated emission levels (BAT-AELs) given in the BREF are expressed as a range of values taking into consideration factors such as the age of the plants, process management and the range of techniques considered to be BAT. The BAT-AELs range from the lower BAT (most stringent) to the upper BAT (least stringent). The BAT AELs are expressed as flue gas pollutant concentrations. While not legally binding under the IPPC Directive, the BAT AELs provide information on the best environmental performance associated with technically and economically viable techniques. A revision of the LCP BREF started in October 2011, a process which is expected to lead to new LCP BAT conclusions to be adopted under the IED in the course of These BAT conclusions will have a much more binding role under the IED than was previously the case under the IPPC Directive. 1.2 Objectives of this report Emissions from existing LCPs are expected to decrease in the future with the implementation of the IED and its more stringent ELVs that are to be met by The publication of the latest 2009 LCPD dataset provided an opportunity to assess the difference between actual emissions reported for that year and the level of emissions that would hypothetically occur were all LCPs to achieve the default IED ELVs. The report also presents a comparison of the reported 2009 emissions with the LCPD ELVs and the BREF lower AELs. It is important to note the theoretical nature of this study. It assumes the same application of the IED ELVs (and the LCPD ELVs and the BREF lower AELs) across all plants covered, and does not consider derogation or the detailed flexibilities (temporary and permanent) that are included in the IED. Thus, the study does not provide a detailed modelling of future IED implementation. The report also does not take into account any changes that may have occurred since 2009 for example, reduced industrial activity because of the economic recession, plant closures, replacement of old plants with newer, more efficient and cleaner technologies, changes in fuel mixes, operational/ management changes and evolution of abatement equipment. 14

17 Data and methods 2 Data and methods 2.1 Datasets used in this study The latest available LCP (2009) dataset (EEA, 2012b) was used as the main data source for the purposes of this report. However, not all required data are available from this source and thus the methodology developed also required certain assumptions and approximations. The Platts EEPP dataset (Platts, 2011) was used to provide more detailed technical information on coal and biomass type used on a Member State basis. The E-PRTR was used for cross checking emissions from the LCP dataset. Each of these datasets has its own terminology, and each also represents a different scale of the emissions sources. At the most detailed scale is the Platts EEPP dataset, in which information is provided for individual units (i.e. boilers, turbines, etc.). One or more units that discharge waste gases through a common stack form a LCP. One or more plants on the same site comprise a 'facility' under the E-PRTR Regulation. These datasets are discussed in further detail below Large combustion plant inventory dataset Starting in 2004, Member States were required to establish an inventory of annual SO 2, NO X and dust emissions from plants under the LCPD (Annex VIII(B)) requirements. The inventory contains information on a plant-by-plant basis including the amount of fuel used per category of fuel (biomass, other solid fuels, liquid fuels, natural gas, other gases). In addition, the Commission has asked Member States to also report for each plant, sometimes on a voluntary basis, information on the rated thermal input, the plant type or sector in which it is operated and its age category. Information on whether the plant has opted-out of the LCPD is also reported. Of the plants in the dataset for 2009, (48 %) met the criteria for further analysis by being identifiable as an ESI or CHP plant and being operational. Of these plants, most (1 592) reported NO X emissions, reported SO 2 and reported dust. The remaining plants were not considered in the scope of this report. The LCPD covers other types of industrial combustion plants beyond ESI and CHP plants such as refineries, and iron and steel facilities. Such facilities were not included in the study. Further, 'opt-out' plants which have elected to manage their emissions via other permissible LCPD methods such as closing down after a set period were excluded, as were those where there was insufficient information to allow their classification. Only the electricity-producing plants, ESI and CHP sectors, are used in this report. Most Member States voluntarily provided the sector codes but a few did not for example, Germany, the Netherlands and Sweden, while Italy only distinguishes between 'refinery' and 'non-refinery'. For these plants it was necessary to use other sources of information to distinguish between a plant producing only electricity (ESI) or also heat (CHP) or only heat (others like refinery or district heating, etc.). The main shortcoming of the LCP dataset for the purpose of comparing emissions with applicable emission limit values or BAT levels (expressed as concentrations) is that the fuel type grouping is not detailed enough to calculate flue gas volumes with a sufficient degree of certainty, especially for 'biomass' and 'other solid fuels'. More specifically, biomass can be solid, liquid or gaseous, and 'other solid fuels' can be (sub)bituminous coal, anthracite or lignite. Each of these fuel types produces a different specific flue gas volume when combusted. The LCP data was therefore complemented by using data from the Platts EEPP dataset at a Member State level to improve the assessment's certainty. The EEPP dataset was used to distinguish between ESI and CHP by assuming all LCPs with gas turbines produce electricity and for all others to determine if the plant was producing only heat or also electricity. Where it was not possible to identify the sector activity of a LCP using this approach for example, industrial parks with several LCPs on the same site the LCPs were excluded from the study. 15

18 Data and methods European Pollutant Release and Transfer Register 2009 dataset The E-PRTR ( 4 ) 2009 dataset (v4.1) ( 5 ) was used to cross-check the LCP emissions data for consistency. The E PRTR provides annual NO X, SO X and PM 10 emissions from industrial facilities covering 65 activities. In 2009, E-PRTR facilities reported being 'Thermal power stations and other combustion installations', of which facilities reported it as their main activity, which is considered equivalent to the LCP ESI and CHP sectors. One or more pollutants were reported by facilities above the E-PRTR reporting thresholds for NO X, SO X and PM Platts European Energy Power Plants dataset (Platts, 2011) The EEPP (version Dec. 2011) (Platts, 2011) is a commercial dataset containing information on most European power plants. The data is available at unit level, which represents a set, block, aggregate or section of power generation equipment. Information on unit name, geographic location, operating status, electrical capacity (MW e ), primary and alternate fuel type (but not fuel use), equipment vendors for the boiler (or reactor), turbine and/or engine, as well as generator/ alternator, steam conditions, pollution control equipment and cooling system data are included in the dataset. The dataset contains more detail on the biomass (wood, peat, bio-derived liquid fuel) and coal (anthracite, (sub)bituminous coal, lignite) fuel types compared to that provided in the LCP dataset. Therefore, for the purposes of this study, the EEPP dataset was linked to the LCP dataset and used at an aggregated Member State level to complement the LCP dataset. The chemical composition of the fuels was used to calculate the flue gas volume with higher accuracy. The following section and Annex I provide further details of the calculations for the different fuel types. In most cases, individual units contained in the Platts dataset cannot be matched with LCP plants and therefore information was aggregated by Member States. The sector code information was used to distinguish between ESI and CHP sectors for Italy, the Netherlands and Sweden. In some cases, the EEPP was not up to date so further information was gathered via publicly available sources. 2.2 Methodology The LCP dataset is the only official dataset available at EU level that contains both emissions and information on the fuel consumption at individual plant level. The Platts dataset was used for increasing the level of detail concerning the coal and biomass fuel types. Together, these datasets provide the necessary parameters to calculate emission levels (based upon ELVs) and make the comparison with actual emissions. Four main steps were performed in the assessment: 1. determination of the thermal capacity, and fuel use per fuel type at each plant; 2. estimation of flue gas volumes; 3. calculation of the theoretical annual NO X, SO 2 and dust (and also PM 10 and PM 2.5 ) emissions when: assuming that all plants have emissions not exceeding the LCPD ELVs; assuming that all plants have emissions not exceeding the IED ELVs; assuming that all plants have emissions not exceeding the BREF lower AELs; 4. comparison of the pollutant emissions calculated for each of the three cases aggregated by Member State with the reported emissions for the year Each step is described in more detail below. Step 1: Thermal capacity per plant fuel use per fuel type To calculate the progress of Member States towards the LCPD and IED ELVs and the lower BAT AELs, knowledge of the thermal capacity at each plant is needed. The LCP dataset contains data on the total thermal input capacity per plant and provides fuel use broken down into five categories: biomass, other solid fuels, liquid fuels, natural gas and other gases. ( 4 ) See ( 5 ) The E-PRTR dataset (v4.1) represents the status of the E-PRTR dataset as on 9 June It contains 2009 data reported in 2011 that has subsequently been corrected by reporting countries. See 16

19 Data and methods Step 2: Estimation of flue gas volumes To calculate the level of expected emissions consistent with LCPD and IED ELVs and the lower BAT AELs, estimates of flue gas volumes were calculated based on fuel type and fuel use information. The calculations start with the estimation of the stoichiometric volumes of flue gases due to the combustion of different fuel types. The combustible components of fuels are principally carbon (C) and hydrogen (H), and in lesser quantity sulphur (S). Complete combustion of a fuel is possible only in the presence of an adequate supply of oxygen (O) usually in the form of air (Box 2.1). Ambient air contains 21 % oxygen, 78 % nitrogen (N 2 ) and 1 % other gases (for example, argon (Ar), CO 2 and water vapour). The products of a stoichiometric combustion with oxygen from the air are CO 2, H 2 O (water) and SO 2, which pass through the chimney along with the N 2 in the air. N 2 and the other gases do not take part in the combustion process, but some N 2 reacts with oxygen to form NO and NO 2 (reported as NO X ). As an example, the flue gas volume in the combustion of 1 kg of light fuel oil is illustrated in Figure 2.1. Annex I provides details of the calculation of the flue gas volume of other fuels (based upon Babcock & Wilcox Co., 2007). For the ideal combustion of 1 kg of light fuel oil containing 86 % carbon, 14 % hydrogen and 0.05 % sulphur, theoretically about 14 kg of air is required. This is the minimum air that would be required if the mixing of fuel and air by the burner and combustion is perfect. The flue gas volume is calculated by taking the molecular weight (m) of the combustible components and air combined in the volume of 1 molecule (mol) of the ideal gas at normalised (N) gas conditions ( mbar, 0 C). This equates to 22.4 L. Using the values in Figure 2.1, the combustion of 1 kg of light fuel oil therefore leads to a net flue gas volume of 12.1 Nm³: CO 2 -gas: 22.4 L * kg/44 m = Nm³ SO 2 -gas: 22.4 L * kg/64 m = Nm³ N 2 -gas: 22.4 L * kg/28 m = Nm³ Water vapour: 22.4 L * kg/18 m = Nm³ = Nm³ (wet flue gas) = Nm 3 (dry flue gas) The dry flue gas volume per unit energy produced (MJ) in a stoichiometric combustion process using 1 kg of light fuel oil is therefore Nm³/MJ using the default net calorific value (43.0 MJ/kg) (IPCC, 2006). Since the LCPD and IED ELVs and the BAT AELs are also expressed as an emission factor per Nm³, the flue gas volumes can be directly used to calculate emissions. In reality, unlike the theoretical example above, combustion works with a surplus of oxygen. The LCPD requirements state that the amount of surplus oxygen depends on fuel type and the technology used (e.g. gas turbine). The following excess oxygen values are used for the flue gas calculations in this report: Box 2.1 Theoretical combustion [C + H (fuel)] + [O 2 + N 2 (Air)] à (Combustion Process) à [CO 2 + H 2 O + N 2 (Heat)] Considering: Such that: 1 mol C + 1 mol O 2 = 1 mol CO 2 à 12 kg C + (2 x 16/12) kg O 2 = (44/12) kg CO 2 1 kg C kg O 2 à kg CO 2 And similarly for H 2 and S: 1 kg H kg O 2 à 9 kg H 2 O 1 kg S + 1 kg O 2 à 2 kg SO 2 17

20 Data and methods Solid fuels (coal, brown coal, wood, etc.): 6 % Liquid fuels: 3 % or 15 % for gas turbines Gaseous fuels: 3 % or 15 % for gas turbines All calculations in this report are based on the calculated dry flue gas volumes and on the net calorific values of the different fuels (IPCC 2006, and for lignite Member State averaged values from Euracoal 2013). It is difficult to estimate accurately the flue gas volumes for biomass and lignite because it itself contains oxygen and this oxygen takes part in the combustion process. Furthermore, the chemical composition of biomass can vary significantly. Since the LCP dataset does not contains details on biomass type (i.e. solid, liquid or gaseous), the Platts dataset was used to obtain further detail on the type of combusted biomass in order to differentiate between Figure 2.1 Calculation of stoichiometric flue gas volume from atomic composition of light fuel oil CO 2 -gas kg wood, peat, biogas (landfill gas, sewage digester gas), wastewater sludge and bio-derived liquid fuel. The Platts dataset shows that 68 % of the units that have biomass as a main fuel use wood, and in most cases wood is an alternative fuel in co-combustion units. In Finland, Ireland and Sweden, peat is also used as a main fuel (11 % of the units). In some cases, there is no extra information available on the type of biomass. As wood is the main biomass fuel type, the chemical composition of wood pellets was used to calculate the calorific value and flue gas volumes for all biomass. Wood pellets are often the main biomass source burned in electrical power plants because of their high combustion efficiency. The pellets themselves are densely compacted sawdust or other wastes from sawmilling, with low moisture content (below 10 %). Furthermore, the ELVs for 'wood' and 'peat' are the same, so there is no refinement necessary for further analysis. The Platts dataset was also used to differentiate between the different types of 'other solid fuels' from the LCP dataset because of the variability in flue gas volumes in the combustion of anthracite, (sub) bituminous coal and lignite ( 6 ). Using the coal details from Platts at a Member State level, the following grouping of coal types was used for the analysis: 1 kg light fuel oil kg C kg H kg S SO 2 -gas kg hard coal consisting of Platts coal types: anthracite, bituminous coal; lignite consisting of Platts coal types: lignite and (sub)bituminous coal; mixed coal consisting of Platts coal mix: bituminous/lignite, bituminous/(sub) bituminous. Air kg (3.399 kg O 2 ) N 2 -gas kg Dry flue gas: kg For each Member State, a weighted average was calculated across the distribution of different coal groups using the electrical capacity (MW e ) of the units from the Platts dataset. Annex II provides a detailed summary. Water vapour (H 2 O) kg Total flue gas: kg Source: Modified from DEB, 1982; and Babcock & Wilcox Co., Step 3: Estimation of NO X, SO 2, dust, PM 10 and PM 2.5 emissions corresponding to the IED and LCPD ELVs and the lower BAT AELs Case 1: All plants have emissions not exceeding the lower BAT AELs Plant-level emissions were estimated using ( 6 ) The value of the flue gas volume corresponding to each fuel type is a sensitive parameter in the assessment. Use of a higher flue gas volume value implies lower emission concentrations will subsequently be estimated. Annex II provides further examples of the flue gas volume calculations by fuel type. 18

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